Manley v. Law

Claudia Manley and Noel Manley, Plaintiffs-Appellants,v.Bruce Law and Hinsdale Township High School District 86, Defendants-Appellees.

Argued
October 24, 2017

Appeal
from the United States District Court for the Northern
District of Illinois, Eastern Division. No. 15-CV-7499 -
Edmond E. Chang, Judge.

Before
Easterbrook, Rovner, and Hamilton, Circuit Judges.

Hamilton, Circuit Judge.

American
politics is not for the thin-skinned. In this case, a dispute
between an elected school board member and a student outside
a high school play escalated quickly. The school board
launched an investigation into the board member's alleged
bullying of the student. The board member and her husband
filed this lawsuit, originally to try to stop the
investigation. After that did not work, the plaintiffs
asserted that the school board and superintendent violated
their federal constitutional rights by conducting the
investigation and publicly criticizing the board member for
her handling of the dispute with the student. The Due Process
Clause of the Fourteenth Amendment, plaintiffs tell us,
protects their emotional well-being and entitles them to feel
that the government treated them fairly. We affirm the
district court's grant of summary judgment dismissing the
case.

I.
Factual and Procedural Background

Because
the plaintiffs appeal the grant of summary judgment against
them, we view the facts in the light reasonably most
favorable to them, giving them the benefit of all inferences
drawn from the evidence in the record. Brunson v.
Murray, 843 F.3d 698, 701 (7th Cir. 2016). This does not
mean, however, that we vouch for the objective truth of all
the facts presented. Id.

Plaintiff
Claudia Manley was a member of the school board for Hinsdale
Township High School District 86 in DuPage County, Illinois.
In the winter of 2015, the district was preparing for a
contested election in April for three school board seats.
Manley was not up for reelection, but her allies on the board
were. On the evening of March 12, 2015, Manley got into a
verbal altercation with a student who was leaf- letting for
Manley's political opponents outside a high school play.
Manley insisted that the leafletting violated school board
policy.

The
altercation between Manley and the student sparked a wider
controversy. The student accused Manley of bullying, and a
wave of support for the student crashed against Manley. The
night of the incident, the student's parents called
Manley and left her several voicemails. When those messages
were not returned, the student and her parents pursued a
public campaign to embarrass Manley that included online
petitions, newspaper articles, and comments at public
meetings, all aimed at removing Manley from her position on
the board. As the pressure increased, the school
district's superintendent, defendant Bruce Law, began an
investigation into Manley's behavior outside the play.
After Law announced the investigation, Manley and her husband
Noel filed suit in state court to enjoin the investigation.

No
injunction was issued, and the investigation ended with no
change in Manley's legal rights or legal status. Manley
has alleged bias and unfairness on the part of the board, the
superintendent, and his investigator, but the investigation
ended with nothing more than a public report finding that
Manley violated a board policy calling for "mutual
respect, civility and orderly conduct" at school events.
The board adopted the investigative report's findings and
formally admonished Manley for violating the board's
policy and for overstepping her authority in attempting to
enforce unilaterally the district's leafletting policy.
Manley is no longer on the school board, but not because of
district action against her. She decided not to seek
reelection in 2017.

As
these events unfolded, the Manleys' lawsuit evolved in
state court from an action to enjoin the investigation to a
suit seeking a declaratory judgment that numerous alleged
procedural irregularities violated state and local law. The
amended complaint, however, also sought damages that
"might, for example, be awarded pursuant to the remedies
provided by 42 U.S.C. § 1983."

Based
on this reference to relief under a federal statute for
alleged federal constitutional violations, the defendants
removed the suit to federal court. The plaintiffs fought to
support their federal claims. Both sides moved for summary
judgment, and the district court granted the defendants'
motion. The court found that the plaintiffs failed to offer
evidence of a required element of a due process claim: the
deprivation of a constitutionally recognized liberty or
property interest. The district court also found that Noel
Manley lacked standing to assert his federal claims. With no
remaining questions of federal law and no diversity of
citizenship between the parties, the district court declined
to exercise supplemental jurisdiction over the
plaintiffs' state law claims through 28 U.S.C. §
1367, remanding the remaining claims to state court.
Plaintiffs have appealed. We review de novo the
district court's grant of summary judgment.
Brunson, 843 F.3d at 704.

II.
Analysis

Bitter
disagreements and harsh words are not new to American
politics. Nearly two centuries ago, Tocqueville wrote that in
American politics, "electioneering intrigues, the
meanness of candidates, and the calumnies of their opponents
… are occasions of enmity which occur the oftener, the
more frequent elections become." Alexis de Tocqueville,
2 Democracy in America 125 (Henry Reeve ...

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